Modern Slavery Act Statement
9 May 2017
This is Capital & Regional plc’s first statement under the Modern Slavery Act 2015 (the “Act”) which applies to companies and partnerships which have a global turnover in excess of £36 million and conduct any of their business in the UK. As required by the Act, the statement reports on the steps that the Company has taken during the financial year ended 30 December 2016 to ensure that slavery and human trafficking is not taking place in any of our supply chains or in any part of our own business.
Capital & Regional is a real estate investment trust (REIT) listed on the London Stock Exchange and with a secondary listing on the Johannesburg Stock Exchange.
Capital & Regional’s core business is owning and managing shopping centres in the UK. It currently owns seven shopping centres in Blackburn, Hemel Hempstead, Ilford, Luton, Maidstone, Walthamstow and Wood Green. It also has a 20% joint venture interest in the Kingfisher Centre in Redditch. The Group’s shopping centre in Ilford was acquired on 8 March 2017. During the year to 30 December 2016 the Group also owned interests in The Mall, Camberley (100%) and the Buttermarket Centre, Ipswich (50%), these were disposed of on 11 November 2016 and 17 February 2017 respectively.
Capital & Regional also has a small minority stake investment in a portfolio of German assets and owns Snozone, which runs the indoor ski operations at Milton Keynes and Castleford.
Across the whole business and on a full-time equivalent basis Capital & Regional employed an average of 260 people during the year ended 30 December 2016. The Group had an annual turnover of £87.2 million for the year ended 30 December 2016.
Our approach to Human Rights
Capital & Regional supports the aims of the Act to combat slavery and human trafficking and improve the transparency of reporting on modern slavery.
Internal Business Assessment
Based on our internal risk assessment, we consider that the risk of any slavery or human trafficking in the employment of our employees is low.
We have a number of policies and procedures in place that we believe promote a culture and behaviours in keeping with the Act’s objectives. These are all set out in our staff handbook and include:
- Anti-fraud, bribery and corruption policies
- Disciplinary and grievance policy
- Equal opportunities and diversity policy
- Grievance procedure
- Health and safety policy
- Whistleblowing policy
Our supply chains include contractors, sub-contractors, goods and services suppliers and professional service suppliers. In most cases we aim to develop long term relationships with our key suppliers by engaging with entities that have similar cultures and values to our own. Following the introduction of the Act, we have reviewed our supply chain to identify the areas that are potentially most prone to slavery or human trafficking.
Our assessment concluded that the highest risk occurred in two areas: firstly where we engage in large development contracts where the completion of the contract may involve the use of subcontractors, and secondly, in the outsourcing of soft services such as cleaning and security.
In the case of the former we take some, limited assurance from the size of the businesses that we engage with, which means that they will need to introduce their own procedures in order to comply with the Act. For future contracts we will consider confirmation of compliance with the Act as part of the tendering process. In the case of the latter we consider the risk is mitigated by engaging with a single well established supplier, VSG Security Group, which is part of Compass Group plc. As part of our review we considered the Modern Slavery Act statement made by Compass Group plc and were satisfied that it demonstrated an appropriate commitment on their part to ensuring compliance with the Act.
The responsibility for reviewing the Company’s ongoing compliance with the Act will be delegated to the Board’s Responsible Business Committee who will report to the Board on its findings.
This statement is made pursuant to Section 54 of the Act and relates to Capital & Regional plc and all its subsidiaries. It is made in respect of its financial year ended 30 December 2016 and was approved by the Board on 9 May 2017.
Capital & Regional plc